Opinion: COAC is a security risk for the U.S.

Dr. Jim Giermanski explains why he thinks the Advisory Committee on Commercial Operations (COAC) needs changes in order to effectively secure U.S. ports and borders

By Dr. Jim Giermanski

February 28, 2011 — CSO —

Many have questioned more than once the value of COAC, especially about its memberships self-interests. But now there is serious question about its role in the security of this nation's borders and ports. COAC's obvious weaknesses are two: first, its latest charter; and second, the self-interest of COAC's non-government membership that places protecting and promoting company and industry values over the greater security of U.S. trade infrastructure essential to our nation's economic base. It has value to the Department of Homeland Security that needs to claim it understands both trade and security for the political agenda of the Administration.

See also: Supply chain security: 5 game-changing forces

COAC's Charter or Purpose
In 2004, the COAC Charter was changed to reflect the added need to be concerned about homeland security within the new Department of Homeland Security's structure and mission. Specifically, the Charter stated:

The Committee shall advise the Secretaries of the Department of the Treasury and the Department of Homeland Security on the commercial operations of Customs and Border Protection (CBP) and related DHS and Treasury functions. It is expected that, during its eleventh two-year term, the Committee will consider such issues as: enhanced border and cargo supply chain security...and the CBP mission, and import safety.

Note: The Committee shall advise...on commercial operations. It is expected that...the Committee will consider... enhanced border and cargo supply chain security. In fact, the word security can only be found 7 times, 6 of which are its use in the title Department of Homeland Security. Words such as container, explosives, WMD, Chemical, Narcotic, Drug, Counterfeit, or Air are not found.

However, the word trade appears 3 times; twice in titles: Deputy Assistant Secretary for Tax, Trade and Tariff Policy and Office of Trade Relations; and as it directly relates to the qualifications of the membership.

Members are selected from representatives of the trade or transportation community served by CBP or others who are directly affected by CBP commercial operations and related functions. The members shall represent the interests of either importers (and their agents) or those associated with the carriage of international freight .... Members shall represent the interest of either importers (and their agents) or those associated with carriage of international freight and are not Special Government Employees as defined in section 202 (a) of Title 18, United States Code.

The Charter allows for subcommittees to be established, presumably to ensure that DHS and CBP obtain information from supply chain security experts. There is a subcommittee called Global Supply Chain Security Subcommittee (Committee).

• Print